2 minute read
Opioid Misuse
Continued from page 1 types of opioids being prescribed and for guidelines that inform acceptable dosages.
For policymakers, the study results imply that “must access” PDMPs increase the time cost of prescribing to physicians for new and established patients and provide an objective information system on the extent of historic opioid use of patients.
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“This suggests substantial
Legal Matters
Continued from page 3 with their internal claims data and comment on / dispute any apparent discrepancies. Keep in mind that some or all of the 2022 projection has likely been paid as discussed below. 340B CEs who submit comments to CMS regarding the payment amounts should request that future data regarding repayment amounts or the claims impacted remain confidential to the extent the CEs exchange claim-level detail.
2. CMS Has Reprocessed and Repaid Many 2022 Claims. CMS states that it already reprocessed most claims with dates of service between January 1, 2022 – September 27, 2022 to be paid at ASP + 6 percent. This accounts for roughly $1.5B of the total $10.5B proposed remedy. CEs should verify whether they received accurate payment amounts at ASP + 6 percent for these claims.
3. CMS Continues to Push Budget Neutrality Argument. CMS proposed decreasing
Financial Forecast
Continued from page 11 higher premium cost.
In some circumstances, if you were covered by health insurance by an individual plan or an employer-sponsored one, you could enroll during a Special Enrollment Period in the future. There is also room for improvement in clinical prescribing guidelines in the ED, and more generally for individuals with a history of opioid use,” said Ukert.
“For health systems, the implications of this study are that despite efforts by state officials, many PDMPs are ineffective. More importantly, providers can implement policies that require access to the system, even when no state mandate exists.”
Having more effective tools to decrease the odds of opioid misuse could help reduce future overdoses and deaths while still allowing the use of these drugs for effective pain management. reimbursement for non-drug items and services to all OPPS providers, except new providers noted below, by 0.5% each year for the next 16 years until the increased amount paid to CEs between CY 2018 –2022 is sufficiently budget neutral. CMS spends a significant portion of the Proposed Remedy Rule discussing its obligation to remain budget neutral and how it will prospectively offset the lump sum payment. This budget neutral rate adjustment does not apply to CEs who enrolled in Medicare after January 1, 2018.
4. Payments from Medicare Advantage Organizations (MAOs) Not Addressed in the Proposed Remedy Rule. CMS had previously issued a memo to MAOs in December 2022, which explained that the non-interference clause prevents CMS from opining on reimbursement between MAOs and CEs because of the contractual nature of the relationship. Many MAOs have stalled issuing repayments until CMS issued this Proposed Remedy Rule, so CEs should now resume pursuing repayments from MAOs based on the terms of their contracts. Of significance, the Proposed Remedy Rule clearly confirms CMS’s position that the default payment rate for all 340B drugs from 2018-September 27, 2022 is none other than the statutory ASP + 6 percent rate. MAO contracts apply the “then Medicare rate” or similar rate language should be closely analyzed in light of CMS’s recognition that there is no other alternative to the statutory ASP + 6 percent rate. an annual Open Enrollment Period for Medicare from October 15th to December 7th when you may change from one Medicare plan to another.
With all these decisions to make before retirement, it is recommended that you talk with a Medicare specialist and work with your CERTIFIED FINANCIAL PLANNER™ to plan for the next phase in of your life.
